The Securities and Exchange Commission has adopted enhanced customer privacy rules regarding security and sharing of nonpublic personal, and account information of clients. These rules primarily are directed at banks and insurance companies, but apply to all financial institutions. As part of these regulations, we are required to issue a “Customer Privacy Notice”, discussing information collected from our clients and our procedures on how to best protect that information.
FACTS
WHAT DOES CAPITOL SECURITIES DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include: Information needed to open an account including social security numbers, investment experience, assets, income, account balances. Information developed as part of financial plans, analyses or investment advisory services. Information concerning investment advisory account transactions, such as wrap account transactions. When you are no longer our customer, we continue to share your information as described in this notice
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons CSM chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does CSM share information?
Can you limit sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For our compliance with rules and regulations – information about your transactions and communications provided to non- affiliated brokerage or investment advisory firms when required to comply with supervisory rules and regulations.
Yes
No
For our marketing purposes –to offer our products and services to you
Yes
No
For joint marketing with other financial companies
Yes
No
For our affiliates’ everyday business purposes – information about your transactions and experiences
Yes
No
For our affiliates’ everyday business purposes – information about your creditworthiness
No
We don’t share
For our affiliates to market to you
No
We don’t share
For nonaffiliates to market to you
No
We don’t share
Who we are
Who is providing this notice?
Capitol Securities Management, Inc.
What we do
How does CSM protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings..
How does CSM collect my personal information?
We collect your personal information, for example, when you open an account or perform transactions apply for a loan make a wire transfer or tell us where to send money tell us about your investment or retirement portfolio become a beneficiary of a trust or an estate We also collect your personal information from others such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes – information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply individually unless you tell us otherwise. Any account holder may express a privacy preference on behalf of the other joint account holders.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Our clearing firm, Raymond James & Associates, is directly involved in the execution and settlement of client transactions. For further details on Raymond James’ Privacy Policy, please visit the following link: https://www.raymondjames.com/privacy-security-and-account-protectionOur clearing firm, Interactive Brokers, is directly involved in the execution and settlement of client transactions. For additional information on Interactive Brokers’ Privacy Policy, please see the following:https://www.interactivebrokers.com/en/accounts/legalDocuments/privacy.php
Joint marketing
A formal agreement between nonaffiliated financial companies to provide or market financial products or services to you. • Our joint marketing partners may include banks and credit unions.
Other important information
CSM understands that the relationship clients have with their Advisory Representative and/or Registered Representatives (“Representative”) is important. If a client’s Representative ends his or her affiliation with CSM and he or she chooses to move to a different Firm, or if an Representative’s relationship with CSM is terminated, the Representative may be allowed to take with him or her copies of all client and account documentation (including but not limited to: account applications; customer statements; and other pertinent forms related to the advisory services provided to the client by CSM), so the Representative is able to continue the relationship with his or her client and continue providing services through his or her new firm. CSM will also retain copies of its client and account documentation.
Questions
If you have any questions about our privacy practices or would like a copy of our full privacy policy, please contact our Compliance Department at 804-612-9700..
